Interpretation ID: nht74-4.36

DATE: 01/03/74

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Lousiana Independent Tire Dealers Association

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of November 14, 1973, to Michael Peskoe of our Chief Counsel's Office, asking whether dealers must record the name and address of the tire purchaser on the appropriate form at the same time the tire is sold. You indicate that most dealers record the information on their sales tickets and put it on registration forms at some later time, as the press of business allows.

The Tire Identification and Recordkeeping regulations (49 CFR Part 574) do not require dealers to record the information on the registration form at any specific time. The "scare stories" to which you refer are not true at all. A recent NHTSA investigation of dealer recording practices was intended only to discover whether dealers were writing down the tire ID number and the purchaser's name, and not whether they were recording the information on particular forms.

The Tire Identification regulation (@ 574.8(b)) requires the information to be supplied to the manufacturer (or person maintaining the information) every 30 days, unless less than 40 tires are sold (your letter to us incorrectly stated less than 60 tires), in which case the information must be reported when 40 tires are sold or 6 months elapses, whichever occurs first.

I hope this clarifies the situation.

SINCERELY,

Nov. 14 1973

Michael Peskoe Cheif Counsels Office Nat Hwy Traffic Safety Admin

Re: Tire Registration & Recordkeeping

A dealer has just contacted me about what seems to be a rather widespread concern.

As we interpret the registration law, a dealer must register his tires at least every 30 days, unless it is under 60 tires pr mo sales, in which case he does not have to turn in this registrations at once.

Because of the time press, most dealers simply get the information on their sales tickets, and then put it on registration forms once every couple of weeks, or as the press of business allows, so long as they get them in once per month.

Now a few scare stpries are going around that if they dont fill in the form right then & there, they will be fined $ 500.00 pr tire.

Before putting out anything to the members, then I wanted to be sure that my understanding was correct. I woild sure appreciate hearing from you.

George H. Jones Manager

Copy: Bill Fowler